Senior Manager, Affirm Bank Compliance

Affirm is reinventing credit to make it more honest and friendly, giving consumers the flexibility to buy now and pay later without any hidden fees or compounding interest.

The Bank Secrecy Act (BSA) Officer is responsible for developing, implementing, and administering the Bank’s BSA/Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT) and Office of Foreign Assets Control (OFAC) Compliance Program to ensure adherence to all applicable laws, regulations, and regulatory guidance, related to unsecured consumer lending and deposits. The BSA Officer provides enterprise-wide oversight of compliance with the Bank Secrecy Act, USA PATRIOT Act, OFAC sanctions programs, and related financial crime compliance obligations. The position ensures that the Bank maintains a strong culture of compliance, effective internal controls, and timely regulatory reporting.

What You’ll Do

Program Oversight: Develop, implement, and maintain the Bank’s BSA/AML/CFT and OFAC Compliance Program in accordance with 12 CFR §326.8, FinCEN regulations, and applicable FDIC and FFIEC guidance.

Risk Assessment: Conduct and periodically update the BSA/AML/CFT and OFAC risk assessments to identify, measure, and mitigate financial crime, terrorist financing, and sanctions risks across the Bank’s products, services, customers, and delivery channels.

Monitoring and Controls: Oversee systems and procedures for transaction monitoring, customer due diligence (CDD), enhanced due diligence (EDD), and suspicious activity detection. Ensure the timely filing of CTRs and SARs as required by FinCEN.

Training; Implement ongoing BSA/AML/CFT/OFAC training for all employees and Board members, ensuring appropriate coverage by role and function.

Independent Testing: Coordinate the independent testing of the BSA/AML/CFT and OFAC Compliance Program, oversee remediation of findings, and ensure ongoing program effectiveness.

Regulatory Reporting and Liaison: Serve as the primary point of contact with